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Simplifying the NIH Policy for Late Application Submission

Posted Dec 19, 2014

This Notice provides information about a new simplified policy for late application submission. Specifically, there is now a two week window of consideration after the application due date, during which time NIH might consider accepting a late application (see details below).

Notice Number:

NOT-OD-15-039

Key Dates

Release Date: December 17, 2014

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Purpose

This Notice provides information about a new simplified policy for late application submission. Specifically, there is now a two week window of consideration after the application due date, during which time NIH might consider accepting a late application (see details below). This is a significant change from previous policy, which tied different late windows of consideration to different types of applications, and provided no late window of consideration for applications submitted to any RFA (Request for Applications) or PAR (Program Announcement) with special application due dates.

The Notice consolidates policy from previous Notices (including NOT-OD-11-035) on late application submission, updates the policy on late applications in relation to changes in other NIH policies and procedures, and includes additional guidance on application submission policies.

This new policy is effective for applications submitted for due dates on or after January 25, 2015. The policy will not be applied retroactively. This means that RFAs and PARs with special due dates published on or before December 17, 2014 will follow the policy described in NOT-OD-11-035.

Policy

Window of Consideration for Late Application Submission

There is a two week window of consideration after the application due date, during which time NIH might consider accepting a late application (see details below). When the application due date falls on a weekend or Federal holiday, and is extended to the next business day, the window of consideration for late submission of applications will be calculated from that business day. Acceptance of late applications will be made on a case-by-case basis, dependent upon the explanation provided in a cover letter submitted with the application.

NIH will not consider accepting late applications under the following circumstances:

RFAs that must be reviewed on a compressed timeline and that have declared, in the Application Due Date field, “No late applications will be accepted for this Funding Opportunity Announcement”.

Application Due Dates Field states: "No late applications will be accepted for this Funding Opportunity Announcement"

*Includes PAS: Program Announcement with Set-Aside Funds

NIH does not expect to accept any applications received beyond the window of consideration or for RFAs that specify no late applications will be accepted.

Please be aware that any reasons for late submission must be in relation to the individual(s) with the PD/PI role on the application. For multiple PD/PI (MPI) applications, the reasons may apply to any or all of the PD/PIs. This accommodation does not apply to co-Investigators, project leaders in a multi-component application, or other Key Persons listed in an application (unless they also have MPI status).

Examples of Reasons Why Late Applications Might Be Accepted

Death of an immediate family member of the PD/PI (or MPI).

Sudden acute severe illness of the PD/PI (MPI) or immediate family member.

Temporary or ad hoc service by a PD/PI on an NIH advisory group during the two months preceding or the two months following the application due date. Examples of qualifying service include: participation in an NIH study section/special emphasis panel, NIH Board of Scientific Counselors, Program Advisory Committee, or an NIH Advisory Board/Council. Qualifying service does not include participation in NIH activities other than those involved in extramural/intramural peer review or NIH Advisory Council/Board service.

For PD/PIs who are eligible for continuous submission (http://grants.nih.gov/grants/peer/continuous_submission.htm), the late application policy applies to activities not covered under the continuous submission policy (i.e., other than R01, R21, and R34 funding opportunities that use standard due dates).

Examples of Reasons Why Late Applications Will Not Be Accepted

Heavy teaching or administrative responsibilities, relocation of a laboratory, ongoing or non-severe health problems, personal events, participation in review activities for other Federal agencies or private organizations, attendance at scientific meetings, or a very busy schedule.

Review service for participants other than a PD/PI or MPI, acute health issues or death in the family of a participant other than a PD/PI or MPI.

Problems with computer systems at the applicant organization, problems with a system-to-system grant submission service, or failure to complete or renew required registrations in advance of the application due date.

Failure to follow instructions in the Application Guide or funding opportunity announcement.

Correction of errors or addressing warnings after 5 PM local (applicant organization) time on the application due date. Applicants are encouraged to submit in advance of the due date to allow time to correct errors and/or address warnings identified in the NIH validation process.

No Advance Permission Is Given for Late Applications

It is important to emphasize that these various examples are just that, examples. No NIH staff member, whether in the Center for Scientific Review or any of the other NIH Institutes/Centers, has the authority to give permission in advance for submission of a late application. Contacting the Division of Receipt and Referral or any other component of the NIH will not lead to either permission to submit late or to the evaluation or approval of the reasons for a delay.

Problems with Federal Computer Systems

Applicants must follow the directions provided at http://grants.nih.gov/grants/ElectronicReceipt/support.htm#guidelines to report Federal computer system issues that threaten the timely submission of a grant application. NIH will investigate reports of Federal computer system issues on a case-by-case basis. If the eRA Commons Help Desk confirms a Federal computer system issue, the application will not be considered late so long as the applicant works diligently with the Help Desk to ensure the submission process is completed in a timely manner. Federal computer systems include: Grants.gov, eRA Commons, ASSIST, SAM (Systems for Award Management), Defense Logistics Agency (CAGE code), and the US Small Business Administration.

Note that problems with computer systems at the applicant organization or system-to-system grant submission service, failure to follow instructions in the Application Guide or funding opportunity announcement, or failure to complete required registrations by the submission deadline are not considered system issues. NIH is under no obligation to accept applications that are late for these reasons.

Reminders

On Time Submission

NIH expects that applications will be submitted on time.

On time submission means an application is submitted error free no later than 5 P.M. local (applicant organization) time on the application due date.

There is no error correction window that extends a submission deadline. This means that an error free, corrected application addressing any errors found by federal systems (e.g., Grants.gov or eRA Commons) must also be submitted by 5 P.M. local (applicant organization) time on the application due date.

When application due dates fall on a weekend or Federal holiday, they are extended to the next business day.

In some cases (see details, below), applications might be accepted after the application due date. A cover letter explaining the reasons for the delay must be included with the application.

While the reasons for late application submission are sometimes personal in nature, specific information about the timing and cause of the delay should be provided so an informed, objective decision can be made. Only the explanatory letter is needed; no other documentation is expected. This letter is available only to NIH staff who have a need to know (such as those with referral or review responsibilities); it is not available to reviewers or other staff.

Applications submitted late, without an explanatory cover letter or outside the late window of consideration, will not be processed, reviewed, or considered for funding.

Terms and conditions of the NIH Continuous Submission policy are not affected by this change in the late application submission policy.